Autumn Budget kpmg.com/uk/budget2018. October 2018
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1 Autumn Budget 2018 kpmg.com/uk/budget2018 October 2018
2 With you today Melissa Geiger Yael Selfin Sarah Churton Harinder Soor Head of International Tax and Tax Policy Chief Economist Partner, International Tax Partner, Claims and Incentives Colin Ben-Nathan Director, Employment Tax Tim Sarson Partner, Brexit International Tax Stephen Powell Senior Manager, Indirect Tax Gavin Shaw Director, Private Client 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 2
3 What are we covering today? 1 Economic outlook 2 Business Tax 3 Employment Tax 4 Q&A 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 3
4 Economic outlook Yael Selfin Chief Economist
5 OBR s significant upward revision to growth in 2019 GDP growth projections (%) % annual change Budget March Statement Budget Source: Office of Budget Responsibility GDP growth for % annual growth March Statement 2018 Budget KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 5
6 OBR now expect a positive output gap for the next 5 years Output gap forecasts % of GDP 0.4 Back-cast Forecast October forecast March forecast Source: Office of Budget Responsibility 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 6
7 Despite slower growth in 2018, public finances are better Changes to net borrowing forecast Net borrowing for , bn March forecast Classification changes Revenue revisions Spending revisions Government decisions October forecast Source: Office of Budget Responsibility 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 7
8 The windfall has been mostly spent Public sector net borrowing % of GDP March forecast October pre-measures forecast October forecast Outturn Source: Office of Budget Responsibility 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 8
9 Not much increase in spending outside of the NHS Cumulative change in real RDEL per capita from Cumulative % change NHS England Excluding NHS England Source: Office of Budget Responsibility 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 9
10 Some of the increase has come at the cost of capital spend Changes in departments' capital and day-to-day spending since March bn Changes in day-to-day spending Changes in capital spending Source: Office of Budget Responsibility 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 10
11 Fiscal mandate target will likely be met with room to spare Projected path for cyclically adjusted public sector net borrowing, % of GDP March forecast October pre-measures forecast October post-measures forecast Fiscal mandate requires this to be below 2% in KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 11
12 The Brexit (double) dividend Cyclically adjusted public sector net borrowing % of GDP Additional 15.4bn kept in reserve against a negative Brexit scenario Current spending plans have maintained a similar margin against meeting the Fiscal mandate of keeping the level of cyclically adjusted public sector borrowing below 2% 2. A favourable Brexit outcome could lead to faster economic growth, than currently forecast. This would lift revenues further, giving the Chancellor more spending room KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 12
13 Public sector net debt to fall over the forecast period Public sector net debt as a % of GDP ` November Budget 2017 March statement Budget Source: Office of Budget Responsibility Supplementary fiscal target for falling public sector net debt as % of GDP in KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 13
14 Abandoning the fiscal mandate creates more room Public sector net debt Additional 73bn, while still keeping to the supplementary target % of GDP Source: Office of Budget Responsibility 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 14
15 Business tax Melissa Geiger Head of International Tax and Tax Policy
16 Introduction We saw a relatively quiet Budget with lots of little bunnies rather than any big rabbits pulled out of the Chancellor s hat as he sought to leave himself maximum headroom to contend with whatever form the UK s exit from the EU takes KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 16
17 What didn t change CT rate Already Trailed Digital Services Tax VAT threshold IR35 extensions Pensions relief Personal allowances and thresholds 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 17
18 Contextualising the Digital Services Tax
19 Digital Services Tax framework 2% on revenues Intermediation activities for UK users Deductible expense but not creditable Safeguards: Double threshold Safe harbour Review Other exemptions Examples Next Steps 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 19
20 Changes related to Intangibles Disposals Corporate Capital Loss Restriction De-grouping charge reform to align pre and post 2002 regimes Acquisitions/onshoring Targeted Goodwill Relief for purchase of IP-rich businesses Disincentivising offshore IP ownership Taxation of income from intangible property in low tax jurisdictions 2018 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 20
21 Capital Allowances AIA Increase Temporary increase for the annual investment allowance from 200,000 to 1m for all qualifying investment in plant and machinery made on or after 1 January 2019 until 31 December 2020 Structures and Buildings Allowance New non-residential structures and building will be eligible for a 2% capital allowance where all contracts for the physical construction works are entered into on or after 29 th October Special Rate Reduction Reduction in capital allowances special rate reduction from 8% to 6% from April Enhanced Capital Allowances (ECA) With effect from April 2020, ECA (100% first year allowance) will be abolished for energy and water efficient assets. This will include the first year tax credit for loss making companies. Alteration of Land Installing Plant HMRC appear to have responded emphatically to their recent defeat at the First Tier Tribunal where it was determined what is meant by the word plant in respect of the alteration of land to install plant KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 21
22 Employment Taxes Colin Ben-Nathan Director
23 Employment Taxes IR35 and the private sector Public sector reforms to extend to large and mediumsized private sector businesses from April 2020 Responsibility for determining whether an engagement falls within IR35 will move to the end user of the services Responsibility for PAYE and NIC will move to the entity paying the Personal Service Company Consultations to be held to inform new legislation, and improve HMRC s Check Employment Status Tool and HMRC guidance Draft legislation expected in Summer 2019, but much for employers to do in the meantime Short Term Business Visitors (STBVs) Administrative easement for STBVs from overseas branches of UK companies UK workday limit for participating in Special Annual PAYE Schemes will increase from 30 days or less to 60 days or less More STBVs from overseas branches (or non-treaty territories) will now qualify for this easement Reporting and payment deadlines pushed back from 19 April to 31 May, in line with Appendix 4 STBV reporting deadline Other matters Employer s NIC on termination payments over 30,000 deferred to April 2020 Employment Allowance to be targeted at smaller employers from 2020 Taylor Review consultations Government response still pending Relief for self-funded workrelated training, no changes proposed Apprenticeship Levy; a package of measures Pension tax relief; Lifetime Allowance increased by CPI from 2019/20 to 1,055, KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. 23
24 Q&A kpmg.com/uk/budget2018
25 kpmg.com/uk/budget2018 The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. The KPMG name and logo are registered trademarks or trademarks of KPMG International.
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